ECB on-site inspections · the Ezelman method

An inspection is decided before the kickoff letter arrives.

We have sat on both sides of that table. Scroll through the 120 days that decide whether the findings letter costs you capital, and what we do on each of them.

D-120 · Foundations

The load-bearing walls are never rebuilt under fire.

Governance, three lines of defence, model inventory, data lineage. If these are not standing when the notification arrives, the inspection is already a remediation programme. Our first week tells you which it is, and we say so before the engagement, not after.

Typical range for a significant SSM finding. Illustrative, not supervisory guidance.

D-60 · Readiness drill

We inspect you before the inspectors do.

A full mock inspection sixty days before kickoff: evidence retrieval timed in hours, interviews rehearsed, one evidence taxonomy across credit, model, data and IT, every document pre-cleared by legal, risk and finance.

FORTRESS

Foundations · Open dialogue · Readiness drill · Taxonomy · Response line · Evidence vault · Supervisory narrative · Sustain. Eight positions held from D-120 through the ITR response.

D-0 to D+90 · On site

One response line. Zero contradictions.

We sit in the room. Daily coordination, real-time interpretation of requests, query prioritisation, escalation management. On the last mandate the inspection team asked for more than eight hundred items; every one was answered from the vault, not improvised.

800+inspector information requests managed, prioritised and answered on one IRB credit-risk OSI
Findings · the response letter

Accept unambiguously. Contest with evidence. Commit to decision dates.

Each finding gets four fields: the bank's position, a dated remediation commitment with a named executive owner, a Board milestone, and the evidence file. The structure below is exactly as submitted and accepted by the JST at first review.

Response to on-site inspection report · IRB [portfolio redacted] · strictly confidential Finding 01 · Severity: Material “The mortgage IRB model's PD calibration relies on a reference dataset that does not adequately capture the 2012–2013 downturn vintage.”
Bank's position: Accepted without reservation. Remediation: augmented reference dataset by [redacted]; one-off prudential margin applied with immediate effect; Chief Model Risk Officer named owner; Board Risk Committee progress reports at [redacted].
See the full specimen letter
Close · the outcome

Zero basis points of Pillar 2 add-on at findings close.

Most recent mandate, closed April 2026: French G-SIB, ECB SSM Joint Supervisory Team, eight months, partner-led. Peer-cohort benchmark for the same inspection vintage: +30 bps. Across every Ezelman-led OSI since 2020, the add-on is zero. By design, not by luck.

The Walk-Away Clause

If your data, governance, or executive sponsorship isn't ready, we tell you before the engagement, not after. If we cannot meet the standard, we recommend someone who can.

20Years inside European G-SIBs
50+1Senior-led mandates delivered
6Countries
100%Senior practitioners

1 50+ senior-led mandates · 20 years inside European G-SIBs. Footprint covers CRR3 implementation, ECB / NCA on-site inspections, stress testing and related advisory. Country scope: France, Italy, Spain, Germany, Netherlands, UK, KSA, UAE.

Typical mandates €250k–€1.5m · senior-only delivery · 5 % referral fee on introduced mandates

Also trusted by: G‑SIBs · ECB/SSM-supervised institutions · GCC Tier‑1 banks · National regulators

The same discipline, on the other three supervisory moments.

Inspections are where it is most visible. The method is the same wherever the supervisor sets the number.

Stress testing & ICAAP

EBA 2027 cycle defence, reverse stress testing as the Pillar 2 artefact the JST reads first, ICAAP calibration the Risk Committee can defend.

Stress testing

CRR3 & the output floor

Group-wide CRR3 ownership from norms to permanent control; Article 494d reversions; the SA-CR, CCF and IRB levers that still work after the 65% step in 2028.

Regulatory programme

Risk & finance transformation

Cost and RWA optimisation, data architecture, target operating model, post-merger integration across credit, market and operational risk.

Transformation

Regulatory radar & intelligence

Forty supervisory dates through 2028, four jurisdictions, long-form essays a CRO can forward. Updated monthly.

Open the radar

The depth of a Big 4 practice. The agility of a partner-led boutique.

Founded by former KPMG Director Hannan Mohammad after 20 years inside European G-SIBs, on their desks and through senior regulatory mandates delivered inside their risk functions. Ezelman exists for one reason: to give Tier-One banks the senior-led, hands-on risk expertise that large firms can no longer consistently deliver.

  • Partner-level practitioners only

    Every mandate is led and executed by senior professionals with direct G-SIB and supervisory experience. No juniors, no learning curves.

  • Battle-tested under supervisory pressure

    We have sat across the table from ECB inspectors, drafted responses in real time, and steered remediation under tight supervisory deadlines.

  • Europe & GCC dual coverage

    Operational in 6 countries. We bring European regulatory rigour to GCC banks preparing for Basel implementation and vice versa.

3G-SIB cohort carousels published in 2026
40Regulatory events tracked on the radar
4Jurisdictions covered (EU · UK · US · GCC)
12K+Words of long-form intelligence published

Recent mandates

View all case studies

In progress · 2026

Completed

CRR3 · Group-wide programme
3-year full programme ownership of the preparation and implementation of CRR3 across credit and counterparty risks — from Norms and Advocacy to Gap Assessment, Data Management, Build and Adaptations, Simulations and Models, Permanent Control and Independent Review, across all geographies.
Group Head of Model and RegulatoryEuropean G-SIB
ECB on-site inspection
Their on-site inspection expertise is practical, senior, and effective. They don't advise from the sidelines — they sit with you in the room, negotiate with the inspector, and own the findings line by line.
Head of Risk & CapitalEuropean G-SIB
PPU roll-out · CRR Art. 494d
Designed and implemented the framework for determining the applicable regulatory approach (A-IRB, F-IRB, SA) and prepared the Permanent Partial Use (PPU) roll-out application package for credit risk across all types of exposures — including Sovereigns and assimilated, RGLA and PSE notification packs under CRR Art. 494d.
Group Programme DirectorEuropean G-SIB

All reference contact details are available on demand.

Q1 2026 Cohort Read

Six EU G-SIBs.
Six capital stories heading into 2028.

A senior-led peer read of BNP Paribas, Santander, Société Générale, BBVA, Deutsche Bank, UniCredit, written for CROs, CFOs and Heads of Capital Management preparing the H2 SREP cycle and the 2027 EBA Stress Test.

The slide shown is one of 12: six scorecards and six 36-month sequences, each a composite of distance to hard minimum, EBA 2025 fully-loaded stress depletion, and P2R level. Cohort-normalised, directional, not bank-disclosed.

Request the full 12-slide cohort read

Next. H2 2026 refresh, publishing this autumn on the Q2 2026 disclosure round.

Source: EBA 2025 EU-wide stress test, Table A2 + Q1 2026 bank disclosures + 2025 SREP letters. Ezelman composite scoring, directional, not a ranking.

Ezelman EU G-SIB cohort read, slide 9 of 12: six scorecards and six 36-month sequences, Q1 2026

What CROs read before the JST does.

View all intelligence

Forty supervisory dates between now and 2028. Each one moves CET1.

Open the live radar
Supervisory milestones · snapshot 1 October 2026 · hover a point
EU · ECB / EBAUK · PRA / BoEUS · Fed / OCCGCC
Supervisory timeline from Q4 2026 to 2028 with key EU, UK, US and GCC milestones Q4 26 Q1 27 Q2 27 Q3 27 Q4 27 Q1 28 Q2 28 Q3 28 Q4 28 TODAY Fed SCB 2026 effective1 Oct 2026 EBA 2027 ST final package · ECB OSI guide revision · end-2026EBA op-risk RTS consultation (EBA/CP/2026/18) closes 31 Dec 2026 1 Jan 2027 · Revised SREP Guidelines apply (EBA/GL/2026/06)PRA Basel 3.1 · FRTB own funds (EU) go-live EBA 2027 ST launch · ESRB scenario · Jan 202763 banks · first climate module SAMA ICAAP cycle · CBUAE thematic reviewsthrough 2027 EBA 2027 stress-test results · SREP 2027 lettersH2 2027 BoE bank capital stress test2027 CRR3 output floor steps to 65%1 Jan 2028 · the first binding step for most IRB banks Basel III Endgame phase-in (expected)US full implementation Jul 2028 GCC full Basel convergence (SAMA · CBUAE · QCB)2028 and beyond
Dates as published by the EBA, ECB, PRA, Fed and GCC regulators; "expected" where a final rule is pending. Full list with sources on the radar.Updated monthly
40Regulatory events trackedH2 2026 – 2028
4JurisdictionsEU, UK, US, GCC
9Compliance areasCRR3, Basel IV, FRTB, ICAAP+
MonthlyUpdatesSnapshot as of 1 October 2026

Recent analysis

Read all posts
April 2026
CRR3 / RTS · 9-min read

RTS on CCF: The Hidden Capital Multiplier Under CRR3

EBA's Regulatory Technical Standards on Credit Conversion Factors will redraw off-balance sheet economics — quantitative impact, IRB own-estimate conditions, and product redesign levers. Where the next 25-35 bps of RWA optimisation hide.

April 2026
CRR3

RWA Optimisation Under CRR3: Where the Basis Points Actually Sit

A practitioner's map of the RWA levers that still work after the Output Floor phase-in — SA-CR calibration, CCF redesign, securitisation retention, and the IRB model changes worth defending.

April 2026
EBA / RTS

RTS on Stress Test Starting Point

The new RTS reshapes how the stress test reference balance sheet is anchored — scope, reconciliation to COREP/FINREP, and material implications for projection engines and CET1 trajectories.

March 2026
OSI

Where Banks Fail on ECB On-Site Inspection

Five recurring failure patterns ECB inspectors flag across IRB, internal governance and RDARR — with the post-inspection remediation arcs we've led at tier-one institutions.

February 2026
Stress test · 11-min read

ECB Reverse Geopolitical Stress Test: A 300bp CET1 Problem

The ECB's 2026 exercise asked each bank to build the scenario that breaks it. Aggregate results were published on 31 July 2026 — and the JST's follow-up questions will be bank-specific.

February 2026
EBA / RTS

RTS on IRB Model Assessment: Materiality of Model Changes

When do IRB modifications trigger a full re-approval vs. ex-post notification? The RTS thresholds, governance implications and practical tests for banks managing large model inventories.

If an inspection is on the horizon, start the clock now.

We recommend readiness work 6–12 months before kickoff. If you are already under inspection, we mobilise immediately. Thirty minutes with a partner, no deck.

No commitment. Confidential. Senior practitioner on every call. Prefer to read first? Request the Ezelman 2026–2030 Regulatory Thesis (8 pages, email required).

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